Review With Opinion Of Value, Out Of State Appraiser! Proteck

[Pittsburgh Pete]

But at the same time, the PA AMC Act Specifically allows the use of out of state appraisers to do review work in PA:

"Section 7. Responsibilities and duties of appraisal management companies [63 P.S. § 457.27] (a) Conduct of reviews.--All appraisal reviews in this Commonwealth must be conducted for an appraisal management company by: (1) a certified appraiser in good standing in this Commonwealth; or (2) a certified or licensed appraiser in good standing in another state."

This was likely intended to allow Standard 3 Reviews for compliance (without opinion of value), required by the AMC act...but it doesn't specify.

Zing!

 

[nachocheesefries]

I was provided a desk review report on a URAR that I performed for a client. The desk review that was made by Proteck was prepared by an appraiser in the state of Washington. This valuation report (Review Appraisal) had a new opinion of value and additional comparables. Zillow was a data source mentioned on his sales grid.

I have a complaint for this prepared, I would like comment before reporting this obvious abuse from the AMC. I do not care about this "Appraiser" from across the continent, but this AMC has state license that should require proper protocol.

I saw one of these!!! I called the appraiser...who was in Kansas City and reviewed a report in Springfield. I told him if I ever saw another one of these crap reports with his name on it...it was going straight to the commission. He, laughed and then hung up on me.

 

[Dublin ohio]

But at the same time, the PA AMC Act Specifically allows the use of out of state appraisers to do review work in PA:

"Section 7. Responsibilities and duties of appraisal management companies [63 P.S. § 457.27] (a) Conduct of reviews.--All appraisal reviews in this Commonwealth must be conducted for an appraisal management company by: (1) a certified appraiser in good standing in this Commonwealth; or (2) a certified or licensed appraiser in good standing in another state."

This was likely intended to allow Standard 3 Reviews for compliance (without opinion of value), required by the AMC act...but it doesn't specify

But would that relieve the reviewer of the responsibility to be geo competent?

 

[Meandering]

But would that relieve the reviewer of the responsibility to be geo competent?

No they are not relieved of the USPAP responsibility.

"Appraisal review." An appraisal review as defined by the Uniform Standards of Professional Appraisal Practice issued by the Appraisal Standards Board.

https://www.yundle.com/laws/pennsylvania/appraisal-laws/pennsylvania-appraisal-management-company

COMPETENCY RULE.
3. recognition of, and compliance with, laws and regulations that apply to the appraiser or to the
assignment.


Comment: Competency may apply to factors such as, but not limited to, an appraiser’s
familiarity with a specific type of property or asset, a market, a geographic area, an intended
use, specific laws and regulations, or an analytical method. If such a factor is necessary for an
appraiser to develop credible assignment results, the appraiser is responsible for having the
competency to address that factor or for following the steps outlined below to satisfy this


Standards Rule 3-1
In developing an appraisal review, the reviewer must:

The reviewer must have the knowledge and experience needed to identify and perform the scope of work necessary to produce credible assignment results. Aspects of competency for an appraisal review, depending on the review assignment’s scope of work, may include, without limitation, familiarity with the specific type of property or asset, market, geographic area, analytic method, and applicable laws, regulations and guidelines.

.

Don't bet that AMC rule extends to opining value, unless there is familiarity with the market and geographic area - and don't forget to sign the report properly according to the state law.

.

 

[Don Clark]

No they are not relieved of the USPAP responsibility.

"Appraisal review." An appraisal review as defined by the Uniform Standards of Professional Appraisal Practice issued by the Appraisal Standards Board.

https://www.yundle.com/laws/pennsylvania/appraisal-laws/pennsylvania-appraisal-management-company

COMPETENCY RULE.
3. recognition of, and compliance with, laws and regulations that apply to the appraiser or to the
assignment.


Comment: Competency may apply to factors such as, but not limited to, an appraiser’s
familiarity with a specific type of property or asset, a market, a geographic area, an intended
use, specific laws and regulations, or an analytical method. If such a factor is necessary for an
appraiser to develop credible assignment results, the appraiser is responsible for having the
competency to address that factor or for following the steps outlined below to satisfy this


Standards Rule 3-1
In developing an appraisal review, the reviewer must:

The reviewer must have the knowledge and experience needed to identify and perform the scope of work necessary to produce credible assignment results. Aspects of competency for an appraisal review, depending on the review assignment’s scope of work, may include, without limitation, familiarity with the specific type of property or asset, market, geographic area, analytic method, and applicable laws, regulations and guidelines.

.

Don't bet that AMC rule extends to opining value, unless there is familiarity with the market and geographic area - and don't forget to sign the report properly according to the state law.

Most states would not allow this. But, and it is a big but, most states do not have jurisdiction over what someone in another state does. To exercise jurisdiction the state would have to file charges and extradite the offender to their state to prosecute the. I suggest you file a complaint with the OCC and through the ASC, and perhaps the Interagency Appraisal Complaint Form the send to www.FDIC.gov/consumers/questions/priv_statement.htm1 or www.helpwithmybank.gov/policies-privacy,htm1 and send a copy to the appraiser in question.


.

Your state likely does not permit this. But, and it is a big but,

I was provided a desk review report on a URAR that I performed for a client. The desk review that was made by Proteck was prepared by an appraiser in the state of Washington. This valuation report (Review Appraisal) had a new opinion of value and additional comparables. Zillow was a data source mentioned on his sales grid.

I have a complaint for this prepared, I would like comment before reporting this obvious abuse from the AMC. I do not care about this "Appraiser" from across the continent, but this AMC has state license that should require proper protocol.

 

[Don Clark]

I was provided a desk review report on a URAR that I performed for a client. The desk review that was made by Proteck was prepared by an appraiser in the state of Washington. This valuation report (Review Appraisal) had a new opinion of value and additional comparables. Zillow was a data source mentioned on his sales grid.

I have a complaint for this prepared, I would like comment before reporting this obvious abuse from the AMC. I do not care about this "Appraiser" from across the continent, but this AMC has state license that should require proper protocol.

Tried to post this earlier and it got messed up. Even if your state wanted to they likely could not prosecute somone for doing this. They would have to extradite them first. Not likely. I suggest you fill ou the appraiser complaint form that is on the web. It is the Interagency appraisal complaint form. google it.

 

[Michigan CG]

Even if your state wanted to they likely could not prosecute somone for doing this.

Maybe I am not remembering this correctly but I am pretty sure Illinois fined someone from out of state.

 

[timd354]

Maybe I am not remembering this correctly but I am pretty sure Illinois fined someone from out of state.

Maybe they tried to, but I would be curious to know if Illinois was actually able to collect that fine or do anything about it if the out of state appraiser without an IL told the Illinois board to go pound sand or simply ignored the IL board.

 

[Terrel L. Shields]

Doesn't this still beg the question? If the "review" doesn't apply the identical SOW, neighborhood boundaries, etc., is it really a review or simply a new appraisal?

 

[jay trotta]

341 COMPETENCY RULE


342 An appraiser must: (1) be competent to perform the assignment; (2) acquire the necessary competency to


343 perform the assignment; or (3) decline or withdraw from the assignment. In all cases, the appraiser must


344 perform competently when completing the assignment.


345 Being Competent


346 The appraiser must determine, prior to accepting an assignment, that he or she can perform the


347 assignment competently. Competency requires:


348 1. the ability to properly identify the problem to be addressed;


349 2. the knowledge and experience to complete the assignment competently; and


350 3. recognition of, and compliance with, laws and regulations that apply to the appraiser or to the


351 assignment.


What does your License Law note in your State ? How have they addressed "AMC" requirements for "Licensing" and posting a Bond ?
after all, it's in the Public Interest;
How & When did the Reviewer gather the Knowledge & Competency (349.) within the past 6 months ? 12 Months ? and if such was gathered, he/she should be familiar with the State Laws & USPAP that are currently applicable to Review Appraiser's.
Good Luck